Self-Implementation Workbook - Ohio Bureau of Workers ...

Governor Bob Taft

Administrator/CEO William E. Mabe

Drug-Free Workplace

Self-Implementation Workbook

Guidebook for employers implementing BWC¡¯s

Drug-Free Workplace Program or Drug-Free EZ Program

1-800-OHIOBWC



Table of contents

Required elements of BWC¡¯s Drug-Free

Workplace Program ....................................................2

Getting started with your Drug-Free

Workplace Program ....................................................3

Developing a written substance policy.......................4

Employee education ...................................................5

Supervisor training......................................................7

Drug and alcohol testing...........................................10

Employee assistance................................................14

10-Step Business Plan for level 2 and

level 3 participants....................................................17

The process of selecting drug-free

service providers ......................................................18

Reporting and documentation requirements............20

Sample policy ...........................................................21

Sample forms ..........................................................27

Self-Assessment Progress Report ..........................31

1

Required elements of BWC¡¯s Drug-Free Workplace Program

Employers participating in the Ohio Bureau of Workers¡¯

Compensation¡¯s (BWC¡¯s) Drug-Free Workplace Program

(DFWP) must implement the following components:

? Develop a written policy;

? Provide employee education;

? Offer supervisor training;

? Conduct drug and alcohol testing;

? Offer employee assistance.

Resources available to help employers implement

requirements

Ohio Department of Alcohol and Drug Addiction

Services (ODADAS) Web address:

odadas.state.oh.us/dfwp/dfwp.asp

Department of Labor policy development tool Web

address: umet-vets.elaws/asp/drugfree/

drugs/screen2.asp

BWC¡¯s procedural guides for the DFWP and the

Drug-Free EZ Program (DF-EZ) ¡ª BWC¡¯s Web site,



2

Requirements

?

?

?

?

?

Develop a written policy

Provide employee education

Offer supervisor training

Conduct drug and alcohol testing

Offer employee assistance

Getting started with your Drug-Free Workplace Program

To put an effective drug-free program into place,

you need to plan carefully. This workbook offers you

guidance on how to develop a drug-free program,

including the order in which you should tackle each

task. Check lists will help you consider everything of

significance for each drug-free program component.

Your program will deter, detect and help you take

appropriate, corrective action to address substance

problems that affect workplace safety and productivity.

Support is available from BWC as you establish your

drug-free program.

In addition, if you are starting a program at level 2 of

DFWP or DF-EZ, or move to level 3 after two years,

you must:

7.

Arrange random drug testing of 10 percent

(level 2) or 25 percent (level 3) of your average

annual work force through a provider that uses

neutral-selection software;

8.

Read the 10-Step Business Plan in this

workbook. Understand what BWC expects of

your company for each of the required steps at

level 2 or level 3.

To put in place a basic level 1 DFWP or DF-EZ, you

should do six things, typically in the order listed below.

1.

Decide how much help you want from

drug-free providers in meeting program

requirements. This workbook provides

guidance in terms of selecting providers.

2.

Compose a written substance policy and

operational procedures. Use the sample

written policy at the back of this workbook

as a guide. Have your legal counsel review

both your policy and operational procedures.

3.

Decide whether to conduct supervisor training

before or after employee education. Contract

with a drug-free provider for these services.

4.

Determine how many drugs you want to test

for in your employees. BWC requires you test

for at least five specified drugs. Then identify

a collection site for alcohol and drug testing.

Inform the collection site testing procedures

should be the same as for federal testing.

Finally, with legal guidance, choose a cut-off

level for a positive test for alcohol.

5.

Decide when to announce your program and its

effective date. BWC recommends you do this

during your first employee education session

where you share your written policy.

6.

Maintain a list of local community resources

employees can use to seek help with a

substance problem. Determine any additional

employee assistance you will offer.

3

Developing a written substance policy

Requirements

? You must have a written substance policy in place

by the 90-day mark of the initial program year.

? First year participants must provide a copy of

the policy to BWC with annual Self-Assessment

Progress Report by Sept. 30 (for the January

program year) or by March 31 (for the July year).

Written substance policy as full and fair disclosure

to employees

For fairness and effectiveness, tell your employees

why you are putting a drug-free policy in place. Inform

them how it works, what they need to know to be in

compliance and the consequences for violating the

policy. Give this policy to all employees in your initial

employee education session where they will learn

about the program. Let them ask questions.

Getting started

1..

2.

3.

4.

Look at sample policies, such as the one at

the back of this workbook, and use whatever

parts you can. Ensure your legal team reviews

the policy.

Make sure you have operational procedures

to guide your supervisors, especially in terms

of how testing occurs. Consider having legal

counsel review your procedures. Enforce your

policy and procedures fairly and consistently.

Ensure compliance with any current union

agreements. Employers with unions must

bargain substance testing.

Make sure your policy says it applies to all

employees from the top person on down.

Other resources

The Department of Labor offers a drug-free workplace

program builder and other useful information at

umet-vets.elaws/asp/drugfree/drugs/

screen2.asp. The Web site includes information on

the Drug-Free Workplace Act (1998), Department of

Transportation (DOT) requirements and other pertinent

laws that may affect your policy.

Presenting the program and policy

1..

2.

3.

4.

5.

6.

Written policy check list

Our company¡¯s written substance policy:

1.

2.

3.

4.

5.

4

6.

Requirements

? You must have a written substance policy in

place by the 90-day mark of initial program year.

? First year participants must provide a copy

of the policy to BWC with annual SelfAssessment Progress Report by Sept. 30

(for the January program year) or by March 31

(for the July year).

Mention your responsibility as an employer for

having a safe workplace.

Focus on responsibilities of all employees for

safety and complying with the policy.

Focus on the help available for employees with

substance problems who come forward

voluntarily. Also, spotlight the consequences

for testing positive.

Ensure your employees understand your

written operational procedures.

Inform your employees when testing may occur.

Make sure employees understand testing

records are confidential.

7.

8.

9.

States management¡¯s reason for creating a

substance-free workplace;

States our drug-free program applies to all

employees, [for public agencies, this includes

elected officials];

Is consistent with collective bargaining

agreements;

Stresses our commitment to confidentiality of

information related to substance test results

and/or requests for employee assistance

related to a substance problem;

States what behaviors are prohibited and the

consequences for violating the policy;

Describes the purpose and content of

educational sessions;

Describes the purpose and content of

supervisor training;

Provides information to employees about when

testing will occur, how testing will occur, what

substances will be tested and under what

circumstances;

Describes the type of employee assistance

offered.

BWC strongly advises legal counsel review your

written policy prior to program implementation.

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